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Concordance Table Environmental Protection and Enhancement Act Approvals and Registrations Procedure Regulation Guide to Content of Industrial Approval Applications and Sections of the Applications for Sour Gas Processing Plants and Heavy Oil Processing Plants Guide to Content

Concordance Table Environmental Protection and Enhancement … · 2016-08-10 · Devon NEC Corporation Pike 1 Project Environmental Impact Assessment June 2012 Concordance Table:

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Page 1: Concordance Table Environmental Protection and Enhancement … · 2016-08-10 · Devon NEC Corporation Pike 1 Project Environmental Impact Assessment June 2012 Concordance Table:

Concordance Table

Environmental Protection and Enhancement Act Approvals and Registrations Procedure Regulation Guide to Content of Industrial

Approval Applications and Sections of the Applications for Sour Gas Processing Plants and Heavy Oil Processing Plants Guide to Content

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Devon NEC Corporation Pike 1 Project Environmental Impact Assessment June 2012

Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 1

Concordance Table – Environmental Protection and Enhancement Act Approvals and Registrations Procedure Regulation Guide to Content of Industrial Approval Applications and Sections of the Applications for Sour Gas Processing Plans and Heavy Oil Processing Plants Guide to Content

Section of Guide Description Locationin Application

3(1) An application must be made to the Director and must be accompanied by the following information relative to the activity, the change in the activity or the proposed amendment, addition or deletion of the term or condition:

(a) The name and address of the applicant 1 General: 1.1 Corporately Registered Company Name Vol 1, Sec 1.2 1.2 Mailing Address of Head Office (in Alberta) Transmittal Letter 1.3 Mailing Address of Applicable Plant or Regional Office Transmittal Letter 1.4 Phone and Telecopier (Fax) Numbers, including e-mail, if available Transmittal Letter 1.5 Date Transmittal Letter 1.6 Name(s) of contact(s) for this application Transmittal Letter 1.7 Signature of Owner/Operator Transmittal Letter

(b) The location, capacity and size of the activity to which the application relates 2 Location: 2.1 Legal Land Description (LLD) - based on Land Status Automated System (LSAS) (i.e., Meridian - Range - Township -

Section - Legal Subdivision) Vol 1, Sec 2.1.2

2.2 Relation to nearest town, city, or village Vol 1, Sec 2.1.2 2.3 Geographical description (topographic map) including relation to nearby watercourses Vol 1, Sec 2.1.2 3 Capacity (stated design, nominal): 3.1 Raw material processing capacity, by-product processing capacity, finished product capacity Vol 1, Sec 2.6.2 3.2 Other appropriate capacity measurements Vol 1, Sec 2.6.2 4 Size: 4.1 Size of the affected area, leased area, and/or plant site (e.g., hectares) Vol 1, Sec 2.1.3 4.2 Physical dimensions of the plant site including a plant site map (i.e., plot plan) Vol 1, Sec 2.11.1, 2.5 4.3 Number of employees working at the facility Executive Summary

(c) The nature of the activity, the change to the activity or the amendment, addition or deletion, as the case may be 5 New Plants: 5.1 Provide classification of this facility under the Environmental Protection and Enhancement Act Activities Designation

Regulation 211/96. Vol 1, Sec 1.5.1

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 2

Section of Guide Description Locationin Application

(c) (cont)

5.2 Describe the general purpose, raw materials, products, by-products (e.g., chemical manufacturing plant, brine pond, waste storage facility, etc.). Include quantities used/produced per unit time.

Vol 1, Sec 2.6.2

5.3 Describe the major unit operations (e.g., cooling towers, steam boilers, compression, sulphur prilling, etc.). Vol 1, Sec 2.6.1 5.4 Describe the duration of the project, construction commencement date, completion date and commissioning dates of

unit(s), production facilities and environmental protection and control systems/procedures. Include an estimated project cost as well as costs of environmental protection and control systems.

Vol 1, Sec 1.4, 1.9

5.5 a) topography of the area; Vol 1, Sec 2.1.2 b) property boundaries and land use of the area; Vol 1, Sec 2.1.2 c) the location of the plant site; Vol 1, Sec 2.1.2 d) location and types of all buildings; Vol 1, Sec 2.6.3 e) exact location and name of all equipment used in manufacturing, processing or storage and other units; Vol 1, Sec 2.6.3 f) liquid effluent outfall and air emission point sources and sampling/monitoring equipment (see ATTACHMENT D)

[provide separate sections on air, wastewater, etc.]; Vol 1, Sec 2.11.1

g) exact location and name of all equipment used in control, treatment and disposal of wastes (see ATTACHMENTS B and C; for landfills see ATTACHMENT E);

Vol 1, Sec 2.10.1

h) location of all sewer lines; Vol 1, Sec 2.9.5 i) the industrial runoff drainage information specified in ATTACHMENT B; Vol 1, Sec 2.9.1 j) location of all air emissions discharge points; and Vol 1, Sec 2.10.3 k) location of all topsoil stockpiles. Vol 1, Sec 2.5.3 5.6 Provide a flow diagram of the manufacturing process(es) or operation(s) involved, the industrial wastewater, air and

waste treatment facilities, and a general narrative description, including equipment and unit capacities. Vol 1, Sec 2.6.2

5.7 Provide a list of unit products resulting from the processing or activity operations, specifying the production unit, typical and maximum design capacities. Include a material balance flow sheet (block diagram) for the entire plant operation.

Vol 1, Sec 2.6.2

5.8 For industrial wastewater discharges and air emission streams identify: Vol 1, Sec 2.9.5, 2.10.1 a) the release substance volume(s) generated per unit time; b) concentration of substance(s), and physical or biological characteristics of substance(s); c) discharge rate per unit time as well as per unit of production, and d) whether the discharge or emission is continuous or intermittent, and the frequency (if intermittent). 5.9 Identify any component streams which contribute to those streams identified in 8 above. Vol 1, Sec 2.9.5, 2.10.1 5.10 Describe any cooling system to be used [e.g., once-through; air (closed-loop); circulating, etc.]. Include flow rates,

intake and discharge temperatures (EC), blowdown rate, dissipation rate in receiving water (kilojoules/hour). N/A

a) Identify any additives (i.e., corrosion inhibitors, biocides), the frequency of application; and b) calculate concentration in the final discharge effluent stream.

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 3

Section of Guide Description Locationin Application

(c) (cont)

5.11 Describe all raw water treatment processes, chemicals used, amounts and quality of wastes to be disposed and the frequency of disposal.

Vol 1, Sec 2.9.4, 2.9.5

5.12 For sanitary wastes, describe the facilities treatment system (if any), and disposal method. Include: Vol 1, Sec 2.10.1 a) number of people on the system(s); b) volume discharged per unit time; c) whether or not approval was required or obtained from the Plumbing Inspections Branch of Alberta Labour; and d) final disposal of sludge (if any) and location. 5.13 Describe major environmental control operations including size and location of any ponds, pond contents, pond liners,

landfills or other waste management facilities (i.e., sludge ponds), air or water pollution control or treatment facilities, discharge details, engineering drawings for these structures (e.g., industrial runoff control, deepwell disposal). (See ATTACHMENT C.) As-built plans and liner details for ponds, landfills, and other waste management facilities will also be required.

Vol 1, Sec 2.9.6, 2.11.5

5.14 For all underground and aboveground tanks, specify: Vol 1, Sec 2.6.1 a) tank locations; b) type of service (e.g., Produced water); c) capacity (in m3); d) material type; e) type of corrosion protection; f) type of secondary containment; g) method of leak detection.

Note: Tabular presentation of data would be appropriate.

5.15 For underground storage tanks, please specify: Vol 1, Sec 2.6.1 a) measures incorporated to prevent overfilling of tanks (e.g., Automatic shut-off devices, high level dams); and b) Summarize results of integrity testing and inspections.

See ATTACHMENT D-A4.

5.16 Describe the source and amount of potable water, how it will be used, and any water treatment system used (i.e., chlorination, filtration, softening, etc.). Refer to Potable Water Regulation 122/93 with amendments up to and including Alberta Regulation 214/96.

Vol 1, Sec 2.9.4

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 4

Section of Guide Description Locationin Application

(c) (cont)

5.17 Provide details on any reciprocating or turbine engines (a table may be used to list all the information if there are several engines):

Vol 1, Sec 2.11.3

a) make and model number; b) rated power (kilowatts); c) exhaust stack diameter (metres); d) exhaust stack height above grade (metres); e) exhaust gas temperature (°C); f) exhaust gas velocity (m/s); g) emission rate of the oxides of nitrogen (grams of NOx)/(kW*hr); and h) does the engine meet the low NOx emission requirement and by what method. 5.18 Provide a copy of the plot plan showing any stack and exhaust stack locations and distance between each stack. Vol 1, Sec 2.11.1 5.19 Provide the peak height of the compressor building in metres. Vol 1, Sec 2.11.1 5.20 Provide details on all natural gas fired heaters (including space heaters), treaters and boilers (a table may be used to

list all the information): Vol 1, Sec 2.11.1

a) rated power (kilowatts); b) exhaust stack height (metres); c) exhaust stack diameter (metres); and d) does the heater, boiler, or steam generator meet the low NOx emission requirement. 5.21 Provide details on any auxiliary or standby process equipment or other sources of emissions to air, soils or water. Vol 1, Sec 2.11.3 5.22 Provide details on flare stacks: Vol 1, Sec 2.11.1 a) height (metres); b) diameter (metres); c) net heating value of the gas to be combusted in the flare under normal and emergency conditions; d) exit velocity of the flare, under normal and emergency conditions; e) method used to control combustion e.g., assisted by air, steam or non-assisted; f) flare tip design, and g) type of igniter, pilots. 5.23 Provide details on any active flare pit on site: N/A a) under what condition is it used; b) type and/or present condition of liner; c) how often it is used and what goes into the pit, and d) type of flare design, e.g., igniter, pilot, etc.

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 5

Section of Guide Description Locationin Application

(c) (cont)

5.24 Details on any inactive or former flare pits on site including: N/A a) size of flare pit;

b) description of previous or planned remediation activities; and c) confirmatory groundwater and soil sample results (if applicable). 5.25 Describe emergency flaring scenarios: provide rates and composition of flared streams (i.e., inlet stream, acid gas

before sulphur recovery unit, acid gas after sulphur recovery unit, etc.) and to provide a dispersion modelling run to show the maximum ground level concentration.

Vol 1, Sec 2.11.1

5.26 Describe any on site incineration of solid waste and any approvals received for the disposal practice. N/A 5.27 Determine the maximum ground level concentration of SO2, NO2, or any air contaminant that is significant. Provide a

computer output for NO2 and SO2 dispersion modelling. Background ambient concentrations must be taken into account, as well as nearby sources up to 5 km.

Vol 2, Sec 4.6 (input/output files provided separately on hard drive)

(d) Where the application requires an approval from the Alberta Energy and Utilities Board or the Natural Resources Conservation Board in relation to the activity, the date of the written decision in respect of the application:

8 New/Renewal/Change: Provide:

8.1 Date of Alberta Energy and Utilities Board (EUB) Approval (if applicable). N/A 8.2 EUB Approval Number (if applicable). N/A 8.3 Comments on any environmental related terms and conditions of the approval. N/A

(e) An indication of whether an environmental impact assessment (EIA) report has been required: 9.1 Was an EIA required? Vol 1, Sec 4.1 9.2 If required, the date of submission of the EIA report to Alberta Environment accepted by the Director. Transmittal Letter

(f) Copies of existing approvals that were issued to the applicant in respect of the activity under this Act or a predecessor of this Act:

10.1 Attach copies of applicable existing approvals (e.g., if this is a renewal application, please attach a copy of the previous approval that is due to expire, including any amendments).

N/A

(g) The proposed or actual dates for construction commencement, construction completion, and commencement of operation:

11 New Plants: 11.1 Provide proposed dates for the above. Vol 1, Sec 1.4

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 6

Section of Guide Description Locationin Application

(h) A list of substances, the sources of the substances and the amount of each substance that will be released into the environment as a result of the activity, the change to the activity or the amendment, addition or deletion, as the case may be, the method by which the substances will be released and the steps taken to reduce the amount of the substances released:

14 New Plants: 14.1 Provide a list and quantity of substances used in the production process in terms of a typical operating day. Vol 1, Sec 2.6.2 14.2 Describe the water or air demands in terms of the sources, purpose (specific operation) and quantities. Vol 1, Sec 2.9.3, 2.9.4 14.3 Describe the sources of the substances to be released to the environment. Vol 1, Sec 2.11.5 14.4 Describe the amount of the substance to be released to the environment. Vol 1, Sec 2.11.5 14.5 Describe the methods of release. Vol 1, Sec 2.11.5 14.6 Describe the minimization controls implemented. Vol 1, Sec 2.11.6, 2.12.2, 2.12.5 14.7 For all plants, the industrial runoff volume for the plant developed area shall be determined. Refer to ATTACHMENT B

for the determination of industrial runoff drainage system design. Vol 1, Sec 2.9.1

(i) A summary of the environmental monitoring information gathered during the previous approval period: 17 New Plants: 17.1 Provide any baseline environmental data that has been collected at the site (for air, water, soils, etc.). Vol 1, Sec 4.0,

Vol 2, Sec 4.0 through 16.0 17.2 Provide baseline hydrogeologic characteristics and groundwater monitoring data (information requirements outlined in

Attachment G). Vol 2, Sec 6.0

(j) A summary of the performance of substance release control systems used for the activity during the previous approval period:

20 New Plants: 20.1 Not Applicable N/A

(k) The justification for the release of substances into the environment as a result of the activity, the change to the activity or the amendment, addition or deletion, as the case may be:

23 New Plants: 23.1 Describe the application of process technology, management practices and current environmental control

technology/control systems towards minimising the release of substances to the environment using pollution prevention approaches and pollution control technologies by:

Vol 1, Sec 2.11.6, 2.12.2, 2.12.5

a) evaluating and identifying alternate process and technologies; b) input (raw materials, feedstocks, fuel, etc) substitution; c) applying industry guidelines and standards; d) referencing similar typical environmental approvals (either locally or in other jurisdictions);

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 7

Section of Guide Description Locationin Application

(k) (cont)

e) considering potential environmental impacts; f) considering unique situations due to plant location, size or capacity; and g) application of ambient guidelines or standards.

(l) The measures that will be implemented to minimize the amount of waste produced, including a list of the wastes that will or may be produced, the quantities and the method of final disposition:

26 New Plants: 26.1 Complete ATTACHMENT A. Vol 1, Sec 2.10.1 26.2 Describe any waste minimization measures to be implemented. Vol 1, Sec 2.10.5 26.3 Describe any liquid effluent/process wastewater or air emissions treatment facilities (see ATTACHMENT C). Vol 1, Sec 2.9.3, 2.9.4, 2.10.5

(m) Any impact, including surface disturbance, that may or will result from the activity, the change to the activity or the amendment, addition or deletion, as the case may be:

29 New Plants: 29.1 Limit discussion to the extent and nature of the surface disturbance that will result from the activity. Include both

temporary and permanent disturbances. Other impacts should be identified in the other relevant areas of this application form such as section (k).

Vol 1, Sec 2.1.3, 2.12.4

(n) Confirmation that any emergency response plans that are required to be filed with the local authority of the municipality in which the activity is or is to be carried on or with Alberta Public Safety Services have been so filed:

Provide emergency response plans related to the disaster plans prepared in accordance with the requirements of the EUB and Municipal Affairs (MA).

32.1 Provide the following information: Vol 1, Sec 3.1 a) statement of confirmation that the plans had been filed; b) date of initial preparation and subsequent amendments to or replacements of the plan; and c) agencies to which the plan has been submitted (e.g., Municipalities, EUB, MA).

(o) Confirmation that there are contingency plans in place to deal with any unexpected sudden or gradual releases of substances to the environment;

33.1 Provide environmental contingency plans to deal with abnormal occurrences which have the potential of adversely affecting the environment. These occurrences need not be environmental emergencies resulting in adverse impacts or even result in contravention of approval limits; but could be occurrences which may result in variations to environmental expectations described in the application.

Vol 1, Sec 3.1

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 8

Section of Guide Description Locationin Application

(p) The conservation and reclamation plan for the activity; 34 New Plants: 34.1 Provide pre-construction site and soil assessments to evaluate and document soil, landscape and vegetation

conditions, including pre-development land and soil inventories, as well as current land use. Identify any environmental risks or constraints for conservation and reclamation of the project, including constraints due to landscape or soil conditions.

Vol 1, Sec 6.1.3, 6.2.3

34.2 Using the pre-site assessments, develop and discuss the procedures that will be used to return the site to equivalent land capability (this may involve returning the site to conditions and land uses that are similar to the pre-development setting or, in some instances, to alternate land use(s) that are different than before). Present the procedures in the form of a Conservation and Reclamation Plan that addresses:

Vol 1, Sec 6.0

a) facility planning • site dimension requirements (including discussion of minimizing surface disturbance); • facility layout (buildings, infrastructure, etc); • grading requirements; • potential impact of the project on landscape aesthetics and plans to minimize such impacts;

Vol 1, Sec 6.1, 6.2

b) land conservation planning (focussing on soil salvage and materials handling) • location and separation of topsoil, subsoil and spoil stockpiles; • topsoil quality, depth, and suitability for reclamation; • areas where topsoil is to be salvaged along with general total volumes; • volumes of topsoil to be used for current uses such as landscaping or for future use in final site reclamation; • subsoil and spoil volumes and suitability for reclamation (if excavations are required for below grade structures); • procedures and equipment to remove soil materials; • problem soil handling (if problem soils are identified); • protocols for suspending and recommencing topsoil salvage when field conditions will result in the mixing., loss,

degradation or compaction of topsoil; • spill control and clean-up procures, including measures to prevent, remove or treat areas of contamination to

meet established guidelines;

Vol 1, Sec 6.3

c) land reclamation planning (at a conceptual level in initial applications for new plants) • end land use objectives for the reclaimed site and how equivalent land capability will be returned; • removal of infrastructure; • contouring and restoration of drainage; • erosion control; • soil replacement; • revegetation and land management, including species list, seed source and quality, seeding rates and methods;

fertilization rates and methods; and wildlife habitat plans where applicable.

Vol 1, Sec 6.2, 6.3

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 9

Section of Guide Description Locationin Application

(q) Any impact, including surface disturbance, that may or will result from the activity, the change to the activity or the amendment, addition or deletion, as the case may be:

37 New Plants: 37.1 Describe any proposed or conducted public involvement process. Vol 1, Sec 5.4 37.2 Briefly describe the target audiences, frequency, type and purpose for the public involvement and any environmental

concerns identified in the review and how those concerns were addressed. Vol 1, Sec 5.0

(r) Information required under any other regulation under the Act to be submitted as part of or in support of the application:

40.1 For example, describe the potable water supply for the plant. Indicate whether it requires approval under the Potable Water Regulation 122/93 with amendments up to and including Alberta Regulation 214/96.

Vol 1, Sec 2.9.4

(s) Any other information required by the Director, including information that is addressed in a standard or guideline in respect of the activity that is published or adopted by the Department.

N/A

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 10

Concordance Table: Additional Items from ‘Applications for Sour Gas Processing Plants and Heavy Oil Processing Plants – Guide to Content’

Note: These items are additional to the requirements identified in the Guide to Content of Industrial Approval Applications

Section of Guide Description Location in Application

Related Section in AENV Guide to Content of Industrial Approvals Applications

3(1) An application must be made to the Director and must be accompanied by the following information relative to the activity, the change in the activity or the proposed amendment, addition or deletion of the term or condition:

(b) The location, capacity and size of the activity to which the application relates 4. Gas Processing Capacity (Raw), Hydrogen Sulphide Processing Capacity, Sulphur Inlet Rate. Vol 1, Sec 2.6.2 3(1)(b)3.1 5. Sulphur Production Capacity, Liquid Hydrocarbon Production, Sulphur Storage Status, Bitumen

Processing Capacity, Other. Vol 1, Sec 2.6.2 3(1)(b)3.1

6. Material Balance. Vol 1, Sec 2.6.2 3(1)(c)5.7 (c) The nature of the activity, the change to the activity or the amendment, addition or

deletion, as the case may be:

1.2 General Purpose, Products, By-products (i.e. Gas Compression and/or Processing, Sulphur production/storage, Condensate storage, etc.).

Vol 1, Sec 2.6.1 3(1)(c)5.2

1.3 Major Unit Operations including a process flow diagram and description of the process. Vol 1, Sec 2.6.2 3(1)(c)5.3 1.7 Water Considerations:

(ii) Sanitary Sewage Handling procedures. If a septic/holding tank is used, specify capacity and material type of the underground tank. In addition, specify what approved municipal facility the domestic wastewater or sludge is taken to for disposal.

Vol 1, Sec 2.9.5 3(1)(c)5.12

1.11 (iv) peak height of buildings (metres), if applicable. Vol 1, Sec 2.11.1 3(1)(c)5.19 1.16 Provide both a computer input and output run (using an acceptable program) for NO2

dispersion modelling to show maximum ground level concentration (MGLC) will not be exceeded (when all continuous point sources are in operation).

Vol 2, Sec 4.6.4 (input/output files provided separately on hard drive)

3(1)(c)5.27

1.17 For a sour gas processing plant (continuous acid gas flaring or sulphur recovery process units with tail gas incinerators, acid gas reinjection plants) and heavy oil processing plants: (i) provide both a computer input and output run (using an acceptable program) for SO2

dispersion modelling (flaring) to show MGLC will not be exceeded (when all continuous point sources are in operation); and

(ii) rates and composition of acid gas and fuel gas flared streams.

Vol 2, Sec 4.6 (input/output files provided separately on hard drive)

3(1)(c)5.27

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 11

Section of Guide Description Location in Application

Related Section in AENV Guide to Content of Industrial Approvals Applications

(c) (cont)

1.18 Emergency flaring scenario: (i) provide both a computer input and output run (using an acceptable program) for SO2

dispersion modelling to show MGLC and an explanation on how emergency flaring will be minimized

Vol 2, Sec 4.6 (input/output files provided separately on hard drive)

3(1)(c)5.25

1.19 Sulphur Storage Facilities (specify amounts stored and in what form, type and thickness of each liner used, how sulphur dusting is minimized, how runoff water is being handled, etc).

N/A N/A

1.20 Describe how benzene emissions from glycol dehydrators are being controlled. N/A N/A 1.21 For heavy oil processing plants, volume of produced gas, concentration of H2S in produced gas

and method of disposal. Vol 1, Sec 2.6.12 N/A

(e) An indication of whether an environmental impact assessment (EIA) report has been required:

2. Was a report prepared? Vol 1, Sec 4.1 3(1)(e)9 (h) A list of substances, the sources of the substances and the amount of each substance

that will be released into the environment as a result of the activity, the change to the activity or the amendment, addition or deletion, as the case may be, the method by which the substances will be released and the steps taken to reduce the amount of the substances released:

1.8 Spill Containment. Process areas such as dehydrator building, refrigeration building, new reciprocating or turbine compressors and amine skids require built in secondary containment for containment of spills. This is accomplished by constructing skids with a built in sub floor “bathtub” type structure or by sloping and sealing the floor and curbing the perimeter with a minimum 75 mm curb (including across doorways). For reciprocating or turbine compressor buildings, AENV will accept spill containment constructed around the specific areas of spills or leaks. Describe how this will be achieved for this gas plant.

Vol 1, Sec 2.12.3 3(1)(p)34.2(b)

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Concordance Table: AEW Guide to Content of Industrial Approvals Applications – Page 12

Section of Guide Description Location in Application

Related Section in AENV Guide to Content of Industrial Approvals Applications

(h) (cont)

Liquid load out and off-loading areas require spill collection devices as a minimum around the hose connection point. This type of device will help ensure the protection of soil and groundwater quality and will lessen cleanup costs. For load-out areas that are very frequently used (i.e. daily or in sensitive areas) containment for truck tank overflow would be required. With respect to liquid off-loading or load-out areas, AENV is requesting that the spill collection devices include the following features: • A lid to keep rain, snow or other materials out of the spill collection device. This will help to

prevent unnecessary contamination of rainwater and lessen the risk of the spill collection device overfilling with rainwater or other liquids.

• The device should be elevated above the ground level in order to prevent rust and to allow for easy inspection of its integrity.

• A device or method to recover any spilled liquids. Some spill collection devices have a built in suction tube that is used to recover any spilled liquid by transfer into the off-loading truck.

Provide a list of all the load-out areas and a description or of how the above will be achieved.

(p) The conservation and reclamation plan for the activity; 1.3 Discuss conceptual plant decommissioning process, including plant abandonment and

reclamation. Vol 1, Sec 6.0 3(1)(p)34.2(c)

(q) A description of the public consultation undertaken or proposed by the applicant; 1.3 Please provide names of newspapers for advertising the application/approval. The newspapers

should encompass all private citizens that may be directly affected by the activity. For citizens isolated from newspapers, please recommend how notification can best be provided.

Vol 1, Sec 5.4.7 N/A